Interpretation ID: 1982-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Transportation Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 17 1982

NOA-30

Mr. E. L. Anderson Project Engineer Transportation Products Inc. P.O. Box 329 Suffern, New York 10901

Dear Mr. Anderson:

This responds to your February 18, 1982, letter asking for an interpretation of Standard No. 217, Bus Window Retention and Release. In particular, you question the requirement of section S5.3.3 which specifies that a continuous warning device shall sound when a school bus ignition is in the "on" position and the release mechanism for an emergency door is not closed. You ask whether depressing the button on the outside of the door should activate the warning device.

The actual requirement of S5.3.3 states that the warning device must be audible when the release mechanism is not in the closed position. The release mechanism is that mechanism that keeps the door from opening. So, for example, if the outside button were depressed but the actual door latch did not open and the door would not itself open, it would not be necessary for the warning device to actuate. However, I assume that the outside button releases the latch which in turn allows the door to open. If this is the case, then at the moment that the latch is released, the warning device must be audible. If this did not occur, it would be possible that the door could be in an open position with the vehicle operating and without the knowledge of the occupants.

I hope that this resolves the question for you.

Sincerely,

Frank Berndt Chief Counsel

February 18, 1982

U.S. Department of Transportation National Highway Safety Administration Office of Chief Counsel 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

We are requesting an interpretation of Paragraph S 5.3.3. of Federal Motor Vehicle Safety Standard 217. The paragraph in question is: "When the release mechanism is not in the closed position and the vehicle ignition is in the "on" position, a continuous warning sound shall be audible at the driver's seating position and in the vicinity of the emergency door having the unclosed mechanism."

The standard two and three point locking mechanism used on our school buses complies with this paragraph. However, in compliance with a specific application for a customer, the van manufacturer's locking mechanism which consists of a push button outside the van body and a pull type handle on the interior of the van body were retained. In order to comply with the aforementioned paragraph, a warning light and buzzer, a door jamb switch and related micro switch and related wiring were installed by us. (Wiring schematic attached).

The question concerns the push button outside the van body that actuates the door release mechanism. Does depressing the button on the outside of the door require a visible and audible device as outlined in paragraph S 5.3.3?

Trusting we have provided you with sufficient information to provide me with an answer in the next few days, we remain,

Very truly yours,

E. L. Anderson Project Engineer

EA/ms Enc. cc: Paramount